The goal of mySociety’s climate programme is to try and reduce the estimated 33% of UK emissions that are within the scope of local authorities’ activities. To be systematic about what that might mean, we’ve tried to categorise all local authority services and activities into three broad areas:
- Service delivery is where councils’ direct or outsourced activities have an implication for emissions. This includes their own facilities, services run directly or those externally procured. For instance, waste disposal and coastal protection are both services in this category, and our initial pass put 71 services in this category.
- Enforcement and regulation is where councils have power to reduce third party/citizen emissions through regulatory frameworks. This might include transport or building regulation, or enforcement of regulations of the private rental sector (80 services).
- Place making is where local government have a coordinating/enabling role in emissions generated by third parties/citizens within their boundaries. This will involve fewer actual duties to take action, but a greater coordinating role, including general planning and research, borrowing and investment powers or strategic economic planning (90 services).
Using the ESD standard list of services provided by local authorities in England and Wales, a first pass identified services that might have relevance to emissions reduction (trying to be inclusive when in doubt). A second pass then assigned those services to at least one of the categories above.
The results of this process are in a GitHub repository. This is an initial test of this concept and the list, and classifications may be refined over time. Future additions might further distinguish powers from duties (where authorities can take action versus when they have to take action) and broad/specific service descriptions.
Internally, we’re using this list as a reminder of the wide range of activities local authorities have responsibility for, and to consider whether different groups of these services may be suitable for similar kinds of external interventions or services we might build as part of our work. As a dataset, this might eventually be able to add value directly to services. For instance the description data could be used in a machine learning approach as described in this paper for tagging and improving search of plans in the Climate Action Plan Explorer.
The Climate Change Committee report on local authorities has two alternate ways of dividing local government functions.
The first is a list of areas of local government responsibility that relate to emissions:
- An overarching role to support the economic, health and social wellbeing of communities
- Powers to ensure buildings meet basic energy efficiency standards
- Duties to prevent homelessness and prevent hazards in housing
- Duties to manage risk including climate risks such as flooding
- Duties and powers to protect the environment, wildlife and heritage
- Duties to collect and dispose of waste
- Borrowing and investment powers
The second is a 6 stage “onion” diagram of activities based on the Centre for Sustainability model, where each layer accounts for a larger slice of emissions, but is less directly under the power of the council:
- Direct control: buildings, operations, travel
- Procurement: plus commissioning & commercialisation
- Place shaping: using powers to control development and transport
- Showcasing: innovating, piloting, demonstrating and sharing good practice, scaling and replicating
- Partnerships: leading bringing people and organisations together, coordinating and supporting others, joining others’ partnerships
- Involving, Engaging and Communicating: translating global and national climate change targets for local relevance, with stakeholders to raise awareness, involving people & ideas for local solutions
Most of these fit into the placemaking category used above, but more generally our approach recognises a distinct regulation role that might be supported in a different way by potential future services to placemaking approaches.
Header image: 愚木混株 cdd20 on Unsplash
The Freedom of information Act is a defence against corruption and incompetence in public life. Arguments to exclude ARIA from FOI do not make a convincing case for an exception, and are part of a broader attack on a pillar of good governance.
The Advanced Research and Invention Agency Bill passed through Parliament this week. This creates a new research investment agency (ARIA), with the unusual feature of the organisation being explicitly excluded from Freedom of Information (FOI).
This is unusual. Very few public organisations are explicitly excluded from Freedom of Information and the few other examples include the Queen and MI5 . How FOI law works is that certain kinds of information are excluded, and so this means different organisations have different amounts of their work open to the public. Existing exemptions around research interests and confidential information mean that similar research bodies can operate within a reasonable balance of preserving confidentiality, space for policy making, and protection of on-going research (see the CFOI briefing on ARIA and an editorial on the topic in Nature). There is no real reason to believe FOI compliance would damage ARIA’s mission… unless you believe that FOI is bad, full stop.
When ARIA was announced, the statement said:
“Noting that ARIA will be a small body with minimal administrative capacity, we will remove the burden of processing Freedom of Information requests.”
This is already fairly negative about FOI, but when it came to defending the policy in the House of Lords, the language got worse. Lord Callanan (a minister at BEIS, which will have oversight of ARIA) called Freedom of Information a “truly malign piece of legislation” that does not achieve “anything at all” and “not much is ever released under freedom of information that causes any problems for government”. Punchy stuff, that also makes you think decision-makers are not opposed to Freedom of Information just for this case. ARIA is the embodiment of a bigger idea that the government takes too few risks, and so should place some risky bets on what is going to succeed in the future. The exclusion from FOI is also part of a bigger idea, that accountability and open government is bad.
You could pick apart the specific arguments made about ARIA, but these aren’t the real arguments, and taking them seriously makes everyone involved sound silly. It’s not credible that even if a well-funded agency received “a disproportionate” number of FOI requests, having a person sit in the corner and process them would substantially impact the mission. If FOI would really trip up ARIA, it is not going to achieve its goals. If, on the other hand, ARIA is going to be staffed with professionals making reasonable decisions on long-bet investments, these professionals could handle a few FOI requests, as professionals do across the public sector.
These arguments are not really about ARIA, and it is not fair to the people tasked with delivering ARIA’s expansive vision that they are starting off under the implication that they have something to hide. The real argument being made is that Freedom of Information is annoying and it stops people doing things they shouldn’t. If FOI was as useless as Callanan says, he wouldn’t care enough to block it, and no one else would care if he did. Indeed, while he was speaking the government was separately dealing with the fallout from the Owen Patterson scandal which was sparked by an FOI request. FOI is an effective way to discover bad things that are happening.
Freedom of Information is swiss-army-knife legislation that stops the need for a thousand bespoke systems of disclosure for every new government agency. Most FOI requests do not discover big scandals, but more than none do, and these have a very big impact. Freedom of Information has a chilling effect on government incompetence and corruption, and those trying to hide from it should be seen as suspiciously as people carrying bin bags of money into a bank.
ARIA is going to be outside FOI, and that’s a shame. But they’re only small in the grand scheme of things. Last year, we outlined a series of straightforward reforms to make the whole system of FOI better and more effective. Over the next year we’ll expand more on how we can improve the power of Freedom of Information, to make sure it continues to expose bad government, and annoy the right people far into the future.
When created, ARIA will be subject to the environmental information regulations, and will be listed on WhatDoTheyKnow, in line with our policy on including authorities beyond the scope of FOI. We would hope that ARIA chooses to answer questions from the public, even in cases where they are not legally required to do so.
Header image: Michael Held on Unsplash
: Technically the ‘Royal household’ and it’s the wider range of security services such as MI5, MI6 and GCHQ.
A month ago we wrote a blog post looking for outside researchers to do some research to keep our climate work well rooted in the evidence base. The goal of this first piece of work is to research public understanding of what local government does, and especially its role in combating climate change.
After a really strong set of applications, we are delighted that we’ll be working with Tom Sasse on this project. Tom is an associate director at the Institute for Government and is taking this work on in a freelance capacity.
As he starts on this research, he’s interested in any material (especially that may be off the beaten path) that could be relevant to that question. He can be reached on Twitter or through email at firstname.lastname@example.org.
We’ll be reflecting on what we’ve learned from this process to make improvements to both the application process, and the design of our future research briefs. If you’re interested in hearing about those future calls for proposals, you can join the mailing list.
- 62% of the public agree that parties should be public with how they instruct their MPs to vote.
- 55% of the public think MPs are personally responsible for their vote, regardless of party instruction.
- The public are undecided on whether the fact that an MP was elected on a party manifesto means they should follow party instructions.
The public think voting instructions should be public
Many votes in Parliament are ‘whipped’, meaning that the party gives MPs instructions on how to vote. This practice is both well known and secretive. While “everyone knows” parties instruct their MPs on how to vote, the instructions are not publicly released.
In late 2021, we worked with Opinium to ask the public some questions to inform our work around TheyWorkForYou and WhatDoTheyKnow. This polling shows that 62% of the public think parties should be public with how they instruct their MPs to vote. Only 8% disagree that this information should be public.
From our point of view, releasing this information would solve a practical problem. TheyWorkForYou makes comparisons between MPs and their party, but to do this it has to calculate what the instruction probably was, based on how most MPs voted. We don’t know what the whip’s instruction was, and so have to work harder to get a result that is inferring what is happening behind closed doors. We also do not have information about the strength of the instruction, and can’t say when a party has a mild preference or a strong opinion about how their MPs should vote.
This information is also important on a principled level. The role of whipped votes is part of the argument about the value of individual MP voting records, where one side argues that MPs don’t really make voting decisions, and so should not be judged individually. If you accept this argument that votes in Parliament are really decided by the party leadership, the democratic case for releasing these instructions is overwhelming.
Voters are unsure on the argument that parties should direct votes
The argument made to the anthropologist Emma Crewe (in her book Commons and Lords) by party whips was that they were performing a democratic function: the people elected the MPs on a party manifesto, and so MPs in Parliament should “scrutinise and improve” but not oppose government plans.
The public is split on how convincing this argument is. We asked if respondents agreed with the statement “MPs are elected on a party’s manifesto, and should vote as the party leadership instructs”. Only 24% agree with this statement, 35% disagree, with 41% neither agreeing or disagreeing. That only a small group outright agree with a philosophy that justifies how Parliament currently works is a problem, but the large group in the middle suggests that the views of the public might be more nuanced about what the role of parties should be in directing votes.
The answer to this question also varies by how people voted in the 2019 election. Labour and Liberal Democrat voters were more likely to move from ‘don’t know’ to ‘disagree’ with the idea that MPs should do as their party instructs, with 43% of Labour voters polled disagreeing and 51% of Liberal Democrat voters disagreeing. This might also reflect an idea that opposition MPs should be less bound by what they said in the last election.
Regardless of why they made the decision, the public think MPs are personally responsible for how they vote
Our polling also showed that the majority of the public (55%) believe that MPs are personally responsible for their vote, with only 15% disagreeing with the statement. This should sound a note of caution for MPs. While it being common practice to follow the instructions of the party is an explanation of how Parliament works, it is not universally accepted this should be the case, or that it removes personal responsibility for their votes in the eyes of the public.
This polling forms part of a wider series of questions that we hope to use to shape our work, and we will share more with you in the coming months.
Thanks to Opinium for providing free polling questions to charities as part of their Giving Tuesday campaign.
Header image: Tim Wielink on unsplash
One of the things we want CAPE, the Climate Action Plan Explorer, to do is make useful comparisons between different councils, and help surface where councils are similar and might be able to learn from each other.
The first go at this was a physical proximity tool, which highlighted neighbouring councils, but this can miss that adjacent councils might well have some different circumstances. As announced in December’s month notes, we’ve now expanded this tool so that it offers five possible ways of seeing which councils are similar to each other.
One of the approaches we’ve been exploring is the use of BEIS carbon emissions data to provide an alternate lens, where councils can be shown to be ‘similar’ on the basis of the overall profile of their different kinds of emissions.
As part of this process we created a prototype using binder and wrote a public blog post to gather feedback (and had a few good Twitter conversations about problems with specific comparisons). We showed the tool to climate officers directly, and also asked a larger group of climate officers and other participants at a session in NetZeroLocal about what aspects they would find useful in comparisons. We also talked to Connected Places Catapult, which is exploring a very similar approach in its Net Zero Navigator.
Generally people were supportive of the idea of making comparisons based on emissions, but raised the point that it might be less or more useful depending on the kind of policy that was being compared.
In the NetZeroLocal session there was broadly a lot of support for urban/rural splits and physical proximity and population size, with then lower support for a range of other options. This included low interest in the abstract idea of the carbon comparison, although in practice this effectively works as an urban/rural split classification.
People also suggested additional datasets for specific kinds of problems. For instance, the rural and urban divide is useful across a whole range of factors, but housing stock would be useful for understanding a comparison of specific policy areas.
The lesson from this is that one single ‘similar’ measure was not going to be good enough. Different kinds of problems require different kinds of comparisons, so we need a framework that can let people choose the comparison they want to make, and datasets that help them make good comparisons. As such, CAPE now works with an improved version of the emissions comparison, but also three other measures, and a composite measure that uses all of these to give an impression of general similarity. This can be used to explore councils, or to limit a text search of plans just to similar councils.
Improving emissions comparison
When we first started looking at emissions data, it quickly became clear there was a set of questions around understanding what the data meant in the first place, whether there was a “correct” way to manipulate it, and then how to describe what it meant at the end.
The original uncertainty about whether it is correct to use ‘per person’ emissions is especially clear for industrial emissions – which have no clear relationship to the number of people in an area. Adjusting by the number of people leads to mid-industry but low-density areas being seen as comparable to very high-industry, high-density areas, which did not seem correct for comparisons. In general, very high- and low-density areas make outliers and for odd clustering. Small authorities in Scotland ended up paired with the centre of London. This affects a small number of councils, but probably reflects patterns that are less obvious (and probably unhelpful) throughout the approach.
There are several approaches to this problem. Connected Place Catapult uses local GDP rather than population as an alternative way of comparing industrial emissions between areas. Another approach would be to explicitly include population density as a dimension of the clustering. This should generally do little for most councils (as it is indirectly reflected in emissions), but should drive a wedge between incorrect comparisons in per person measures. Another option is to cap (winsorization) the population used to calculate per person. This should stop extreme outliers presenting bizarrely in comparisons without excluding them completely.
For v2, we tested a few approaches and in the end used versions of all of these. The raw emissions data is adjusted in the following ways:
- Domestic emissions are adjusted to be per person
- Commercial and industrial to be per unit of GDP
- Transport and Public Sector are per person, but winsorized.
- A weighted down version of population density is used as an extra factor to push dissimilar councils a little bit further apart.
This produces clusters that are broadly similar to V1, but passes the test of not grouping a set of councils that seemed incorrectly grouped in the original.
We also took a different approach to labelling these groups. Feedback was positive for the urban/rural distinction in V1, but this is now being taken care of more directly through a different approach.
Given this, the labels for emissions data focus on which aspect of emissions the grouping has a higher than normal distribution of. While there are also times where a grouping has a below average amount of emissions for a particular type, this was hard to condense into a quick label (below average is not ‘low’) and is expanded on in the description.
Label Description Industry/domestic/transport Above average for industry/domestic/transport, below average public sector emissions. Public sector Well above average public sector (government, education, health), below average in other areas. Urban mainstream Below average for most emissions scores. Domestic Slightly above average in domestic emissions, below average public sector emissions. Industry/commercial/public sector Above average industry/commercial and public sector. City of London The City of London does not have a comparable emissions profile
For the moment we are not displaying these labels in the interface, but may use them as the basis for other forms of comparison in future. In general, this process is inherently throwing away data to make comparisons easier, and so will always break down at some level of analysis. The solution to this is not to make the approach perfect, but to present multiple options that meet different use cases.
From feedback we learned that we couldn’t solve everyone’s problems with the same measure of similarity, so we’ve gone away and created a few new measures, and a framework where we could add more in future.
This includes the previous measure of which councils geographically border or overlap with the selected council and introduces three new measures, deprivation profile, rural/urban profile and a composite overall comparison.
The similarity between authorities is calculated by the proportion of the population living in high deprivation (1st quintile), medium deprivation (2nd-3rd quintile) and low deprivation (4th and 5th quintile) neighbourhoods. The population density is also used to help distinguish between authorities with very similar profiles of deprivation.
This UK-wide comparison is based on a Composite Index of Multiple Deprivation system.
The similarity between authorities is calculated by the proportion of the population living in urban, rural, and highly rural neighbourhoods in an authority. The population density is also used to help distinguish between authorities in entirely urban areas.
This UK-wide comparison is based on a Composite Rural Urban Classification system.
There is also an overall comparison, which is the default view. This takes all of the above, and calculates which councils are nearest to each other along all these measurements. Councils may be shown as overall highly similar because they are very similar in one degree, or because they are slightly similar across several.
Our thinking in this was to create a single measure that was likely to be slightly useful in most cases, while giving more advanced users additional tools to dig into specific comparisons.
The underlying datasets and code are available on Github.
- Online version of this document
- Application form
- Q&A Event on 14th January 2022
- Join the research commissioning mailing list/Research pool
- UPDATE: Q&A Session video
In one sentence
mySociety is looking for an individual, organisation or joint team to research public understanding of what local government does, and especially its role in combating climate change, primarily through conducting a literature review, to be completed by the end of March 2022.
Established in 2003, mySociety is a not-for-profit group, based in the UK but working with partners internationally. We believe that people can and want to work together to build a fairer society, to tackle the most pressing crises of our age. mySociety’s role is to use our digital and data skills to help this repowering of democracy. We build and share digital technologies that help people be active citizens, across the four areas of Democracy, Transparency, and Community and Climate. Our projects include TheyWorkForYou, WhatDoTheyKnow, and FixMyStreet. We also conduct and commission research in our areas of interest, which includes our new Climate programme. Our research programme is concerned with ensuring we are producing tools and approaches that are a good fit for the problems the organisation is trying to address.
About mySociety’s existing work in this area
The starting point for mySociety’s Climate programme is that around a third of UK greenhouse gas emissions are within the power or influence of local authorities and their communities. Through the deployment of data and digital services, we are helping councils, community organisations, campaign groups and individual citizens to take faster, more informed and effective action to cut emissions at the local level. Our initial project is a website that makes local authority climate action plans more discoverable and searchable. Our Climate programme seeks to support engagement from citizens, action from local government, and better information for all. You can read more about mySociety’s Climate programme here.
Other areas of our work have involved local government and local democracy. Previous mySociety work of relevance to this project includes Participation vs representation: Councillor attitudes towards citizen engagement and Assessing success in Civic Tech: Measures of deprivation and WriteToThem.
About this project
We want to decrease UK carbon emissions that are either directly controlled or influenced by local government (see Climate Change Committee report on role of Local Authorities). Our hypothesis is that people know relatively little about local government, relatively little about the idea of Net Zero, and even less about the intersection of the two. If this is true, there are opportunities to improve public/campaigner knowledge that would help align public pressure and campaigns with the biggest opportunities for emissions reduction through local government. But, similarly the reasons for low understanding of local government may present barriers to this approach that need to be addressed.
We want to understand what people know about what local government does, what actions people think “the government” in general needs to take to reduce emissions, and where there is alignment/mismatch between where people put responsibility for changes, and the reality of local government areas of responsibility.
We would like a short literature review to clearly summarise existing work on these questions. We may also commission some polling (up to three questions) on this topic during the course of the project. If so, we would hope the research could help us shape the polling questions, and that the results would be included in the review (polling costs themselves should not be included in the budget). Useful sources are likely to include public opinion work conducted by polling companies, organisations like NatCen, and specific projects such as the Hansard Society’s Audit of Political Engagement. Work by organisations focused on local government, such as the Local Government Association and New Local, may also be helpful.
The available budget for this work is up to £5000-8000 (inclusive of VAT), and the project would need to be completed by the end of March (around 4-6 weeks from end of commissioning process).
The main audience for this work will be mySociety, as we seek to understand how best to develop our Climate programme. However, we would hope it would be of wider use to other researchers and the interested public, and in line with our general approach, would plan to make the outputs public. Our default assumption is that the main output is a single written report, that will be edited to our style, and published on our research site, with a short 500-1,000 word summary that can stand alone from the document. We are open to proposals on the length and form of the outputs (for instance, if you believe the problem is better solved by a series of linked shorter pieces). We are also open to variations on the approach/research method if you believe it might provide a useful answer to our problem.
What we are looking for in and from a partner
Expertise/ skill set
While all projects benefit from subject expertise, we believe this project could be completed without a huge amount of prior experience with the local government/net zero problem, with knowledge of local government being more important.
Being able to understand our problem, effectively summarise available information, and work productively with us are also key factors. We will especially be looking for clarity of written communication. The proposed output should be focused on informing future decisions mySociety makes and so should be simple, concise and well-written. We will provide access to the mySociety research style guide which the project will eventually be edited to.
Alignment with values and aims
Our Repowering Democracy strategy puts a special emphasis on embedding equity and inclusion in our work practices and services, and our work aims in general to fulfill values of equity/justice, openness and collaboration.
Applicants should consider if this presents any obstacles to a working relationship, and think about how these values should be reflected in the project plan, either in terms of subject matter to investigate, or research approach. For instance, within the bounds possible given what has been written, we would be interested in strategies for ensuring a reasonable gender balance in authors cited.
mySociety works flexibly and remotely, and there is no requirement to work from or visit an office. Applicants can distribute their work as appropriate over the time available, but we would expect regular check-ins on progress to be arranged over that period. A shared slack channel and a specific contact person will be used to help coordinate and quickly share questions and information between mySociety and the researcher.
Successful applicants would be expected to abide by the mySociety Code of Conduct in mySociety communications channels and events.
Outputs and deliverables
The production of a literature review in around 4-6 weeks (deadline by the end of March 2022), a summary of this research and an internal presentation of the research to mySociety staff. To be discussed: the usefulness of public polling, and any specific areas there is a lack of evidence.
Q&A and contact details
The application timeline includes a Q&A event, which you can sign up at the link at the top of this document.. The Q&A session will include an element to help individual researchers coordinate to form a joint submission (applications are also welcome from individual researchers). Answers will be made available in a video on this page for applicants who cannot take part. Questions can be emailed to the contact address below.
Please send any queries or questions to email@example.com and mention which project it is in regard to. Questions in advance are preferred and will be prioritised in the session.
Applications can be submitted by individuals, organisations, or joint teams of individuals/organisations. These should be sent to firstname.lastname@example.org by the closing date.
You should submit a short application, of up to 4 pages of A4. A template for the response can be download at the link at the top of this page, and covers:
- Who you are (whether an individual, organisation, or joint team).
- A description of your previous experience/previous work and why you want to take on this project.
- To the extent that this is possible, this should be anonymous and not include names of the org or members of the team (to help with anonymous stages of the recruitment process)
- How you would approach and deliver this project – a short project plan with approximate timings.
- This could include discussion of whether the suggested approach – a short literature review – is the right one for what we want to achieve, and any possible alternatives.
- The total value (£) of your proposal (including VAT), and high-level breakdown of costs (perhaps an indication of days per person, any other expenses). This does not need to include production costs of the report.
- Given the cost of the project, we will not be giving a great deal of weight to budget plans so please keep this short and high-level – we can dig into further details during interviews, if necessary.
- A short description of the individuals or team who will do the work, including biographies
A separate equalities monitoring form, which can be filled out online and is processed separately from the main application (there is a link to the form in the application form). This is for understanding the reach of our method of distributing the call for proposals.
If you are interested in joining a ‘researcher pool’ mailing list that we will contact with details of future projects, please see the link at the top of this document.
If there are changes during this timeline, the table on the website version of this form will be updated.
Stage Date Description Call for proposals published 6 January 2022 Q&A Webinar 14 January 2022 An open, online public event for interested bidders to learn more about the project and ask questions. This will be recorded and available afterwards. You can submit questions in advance to email@example.com. Questions in advance are preferred. Questions answered 17 January 2022 Video of the webinar to be made available to all potential bidders, in addition to answers to any other questions submitted via email Deadline for applications 21 January 2022 (end of day) Initial decisions 27th January 2022 Applicants to be informed whether they have made it through to a short panel interview (and may be asked for a sample of existing work). Applicants not progressing past this stage to be offered written feedback Interviews w/c 31 January 2022 Format to be decided, but this will likely be a one-hour panel interview with several people involved in the climate programme, towards the end of the week (3rd, 4th Feb) Final decision w/c 8 February 2022 Remaining applicants to be informed of the final decision. Applicants not progressing to be offered feedback Project briefing/kick-off meeting End of w/c 8 February 2022 To include a brief introduction to mySociety, discussion of any onboarding required and approach to project management, communication and catch-ups Project deadline 31 March 2022 End of project
What happens after the project
We intend to publish the report you produce, credited to you, on the mySociety website, licensed under a Creative Commons licence (see recent publications on research.mysociety.org for details). We may make some light edits (beyond proofreading) before we publish. You will be free to make publicly available your own version should you wish to, and any other material based on the research you conducted.
We will convene a short ‘lessons learned’ session to discuss how the project went – what went well and anything that could have been improved. We will also discuss any future work based on the delivered project (eg if you are an academic and might want to co-author an article) and our ongoing relationship. We would also like to arrange a presentation on the project to mySociety staff, and there may also be an opportunity to promote the work in a public event held by mySociety (budgeting for this would be separate to the project above).
Terms and conditions
Interested parties must be UK-based individuals or organisations.
Work must be completed by the end of the financial year (31 March 2022).
After getting a lot of helpful comments and conversations (thank you), Gavin put what he learned into a document that is helping us shape our commissioning process. While aimed at a relatively small organisation, a lot of the general lessons and thinking should apply to organisations of any size.
We will announce a few calls for proposals over the next few weeks and give this process a go. At the end of the projects, we will do a follow-up post on what we’ve learned.
Header image: Photo by Matt Duncan on Unsplash
We’re going to be commissioning several pieces of research as part of our Climate Programme over the next few months. We’ve not really commissioned research – publishing a proposal and inviting individuals and organisations to bid for it – before, so we want to build a new process we can use for our climate work and other projects across mySociety in future. We’re working with freelance consultant Gavin Freeguard to help us design this process.
As part of developing that process, we’d love to hear from you. Have you had experience of commissioning research, and do you have views on what a good process looks like? Have you been on the receiving end, bidding for work, and do you have insights about how we can make things as straightforward and as effective as possible? If so, we’d be really interested in speaking to you – please get in touch at firstname.lastname@example.org (or put a comment below).
We’re keen to explore all the parts of the process, including:
- How to develop a proposal, including calculating budgets and timescales
- Where to advertise, what to include in the published proposal and other information those bidding for the project would find helpful
- How to assess applications and award the work
- What to provide to successful applicants, to help them work with mySociety as seamlessly as possible
- How to manage the project and assess progress as the work is conducted and concluded
- How to evaluate the project and learn lessons once the work has been completed
- How to maintain a relationship with the commissioner researchers/organisation.
We’re planning to publish a short report in the next few weeks summarising what we’ve learnt from others and how we plan to commission research in future. We want it to capture the best examples of what organisations are already doing and support other organisations who may need to develop a similar process in future. So please do get in touch if you have any ideas: email@example.com
Header image: Photo by Matt Duncan on Unsplash
The government is currently consulting on its plans for a new framework around data (‘Data: a new direction’). This involves changes to the structure and powers of the Information Commissioner (ICO), the office responsible for regulating and enforcing a set of legislation that includes both data protection and Freedom of Information.
In April this year, we published a report “Reforming FOI”, which among other changes argued for improving the funding of this organisation’s access to information functions. We also argue that changes in the importance of data protection over the last 20 years make the case for splitting off Access to Information into a different organisation, in particular as the Information Commissioner tends to be recruited mostly for their data protection expertise.
The language in the current consultation is around bringing the ICO into line with other ‘economic’ regulators, who mainly regulate private sector activity (OFCOM, OFGEM, etc). Part of this would involve a switch from a ‘corporate sole’ model (there is a person, ‘the Information Commissioner’), to a governance board model, where the ‘Information Commissioner’ is the chair of a statutory independent board with the commission itself run by a CEO.
The consultation is generally focused on the data protection roles of the organisation, but changing the governance of the ICO as a whole would have important knock-on impacts on their Access to Information work. Our reply to this consultation focuses on the impact on Freedom of Information.
- We are supportive of a board structure for the ICO as a way of bringing in additional expertise. We recommend a specific seat for FOI/Access to Information expertise. This seat should be appointed by Parliament.
- We believe that the appointment process for the Chair of the board (the new ‘Information Commissioner’) needs to substantively include Parliament and give them the ability to reject the government candidate.
- We oppose measures to extend government control over strategy and CEO appointments beyond the situation for comparable regulators.
- More generally, reform of ICO governance is an opportunity to set regulation of Access to Information on a more sustainable and independent path.
- A strong sign that the independence of the FOI functions is considered important would be to transfer funding from DCMS to a parliamentary process similar to the Parliamentary and Health Services Ombudsman and the Office of the Scottish Information Commissioner.
- It should also be considered whether the different long term directions of the ‘privacy’ and ‘Access to Information’ functions of the organisation mean it would be appropriate to divide the Commissioner’s Office, and create funding and oversight structures appropriate to each branch.
Our full reply can be read here.
The deadline is 19th November if you or your organisation want to submit a response.
The ODI has a guide to the consultation to help you identify relevant areas. For more background, the ICO and Biometrics and Surveillance Camera Commissioner‘s responses present their views on proposed structural reforms. The Institute for Government organised a roundtable on the proposed ICO reforms, and a summary can be read online. The Legal Education Foundation has commissioned an analysis on the equality impact of the proposed changes.
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The House of Commons Public Administration and Constitutional Affairs Committee is currently conducting an inquiry into the Cabinet Office’s Clearing House function. We have submitted written evidence to the Committee building on our recent report “Reforming Freedom of Information: Improvements to strengthen access to information in the UK”. We outline how tactics used by the Cabinet Office fit into a wider pattern of evasion, and how Scottish FOI legislation provides a model for how these issues can be addressed.
Our full submission can be read online, or downloaded as a PDF. Written evidence from other organisations and individuals can be found on the Parliament website. A summary of our evidence and recommendations is below.
- The Clearing House, and/or any other FOI coordinating body, should be compelled to operate in a fully transparent manner, publishing its procedures, decisions and appeals data.
- The Freedom of Information Act (FOIA) should be revised to improve clarity of process and to close procedural loopholes that currently frustrate disclosure and effective regulation.
- FOIA should be revised to include a legal obligation upon public authorities and the regulator to collect and publish data on the administration of the Act.
- The regulation of the FOIA should be split from the current Information Commissioner’s Office, where its budget and importance is dwarfed by data protection work, and constituted as an individual entity focused solely on FOI.
- The oversight of the FOI regulator should be migrated from its current Ministerial portfolio, where it is vulnerable to political pressure and influence, and should instead become accountable to Parliament.
Q1: The Cabinet Office’s compliance with and implementation of the Freedom of Information Act 2000
- Central Government statistics
- ICO decision notices
- Procedural complaints
- Relevance to Clearing House
Q2: Role and operation of Clearing House
- History and available information about the Clearing House
- Addressing the core problem
- Directly addressing delay and obstruction tactics
- In official statistics, the Cabinet Office stands out as having a lower than average percentage of requests for information fully granted, and a higher percentage of requests that were not returned within the 20 day statutory limit.
- The Cabinet Office has received a high number of decision notices from the ICO, with over 50% of complaints upheld or partially upheld in all but four years (2014-2017).
- The highest number of complaints are upheld in procedural areas, which, taken in combination with wider patterns and specific decisions, are reflective of tactics used to delay or obstruct the release of information. For instance, administrative silence/stonewalling can be a highly effective tactic to delay the long term release of information.
- While a coordinating function can be legitimate, that the Clearing House is based in the Cabinet Office is a cause for concern. There is a key question of whether the Clearing House reduces the volume or quality of information disclosures through permissible or impermissible means.
- Evidence from the information tribunal concerning the release of information related to the Clearing House should be seen as informative as to the general attitude towards transparency: by default withholding everything, and using every tool to delay scrutiny of this decision.
- FOI requests should be ‘applicant’ and ‘purpose’ blind. The storage of unnecessary information about the applicant in the Clearing House system is an information hazard that raises reasonable suspicions that requests are not being treated as legally required.
- However, fixing the underlying problem requires more than changes in which information is gathered and stored. Impermissible methods (such as higher scrutiny for journalists) can be reframed as higher scrutiny for particular kinds of requests (that are likely to be requested by journalists). The root problem requires more effective ways of ensuring the correct information is made available promptly.
- In general, concerns about coordinating bodies undermining the functioning of the Act should be directed at closing loopholes they (and any public authority) can use to delay or obstruct the release of information.
- We recommend mirroring the approach used in Scottish Freedom of Information legislation to provide stronger clarity around time scales and administrative silence that can prevent delaying tactics.
- More generally, the system of regulation could be improved by moving supervision and funding of the Information Commissioner’s FOI functions from government ministerial oversight (where there is clear capacity to limit resources for FOI enforcement) to Parliament.
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